Doyle A. King - Page 4

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          for failure to pay estimated tax pursuant to section 6654 for 1990 and      
          1991.                                                                       
               (15) Whether respondent correctly applied the Consumer Price           
          Index (CPI) to petitioners' 1989 joint return figures to determine          
          petitioners' 1990 and 1991 tax liability, and to establish asserted         
          increased liabilities.                                                      
               Respondent concedes that petitioners are entitled to a filing          
          status of "married, filing joint return."                                   
                                     FINDINGS OF FACT                                 
               Some of the facts have been stipulated. The stipulation of facts       
          and the attached exhibits are incorporated herein by this reference.        
               Petitioners were residents of Stockton, California, when they          
          filed their petitions. Doyle is primarily a real estate broker. In          
          1990 and 1991, and in prior years, he owned and operated a real estate      
          brokerage business under the name of Delta Valley Realty (Delta             
          Valley). During 1990 and 1991, Yvonne worked at Delta Valley as a real      
          estate agent.                                                               
               In 1990, Yvonne received non-employee compensation income of           
          $111,855 from Delta Valley as reported on a Form 1099. In the same          
          year, she had Form 1099 non-employee compensation income of $1,998          
          from Phoenix International Marketing Corporation of Sparks, Nevada.         
               Neither petitioner filed a timely Federal income tax return for        
          1990 or 1991. However, copies of signed joint returns for 1990 and          
          1991 were stipulated. Respondent's opening brief states that these          






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